1. To what extent is the approach to tackling violence against women, domestic abuse and sexual violence is improving as a result of the obligations of the Act.

New Pathways is not able to identify a significant improvement to the approach to tackling violence against women, domestic abuse and sexual violence in recent months and would be reluctant to conclude that any improvement that has been observed is the result of the obligations of the Act. This is not to say that New Pathways does not feel that the obligations of the Act could well lead to a significant improvement but we feel that it would be premature to make an assessment of this nature at this time.

2. What are the most effective methods of capturing the views and experiences of survivors? Are arrangements in place to capture these experiences, and to what extent is the information being used to help inform the implementation of the Act’s provisions.

New Pathways feels that it is important to involve survivors in the development of specialist services wherever practical and possible. New Pathways acknowledges that a consideration of survivors’ views and experiences is crucial and may well be the best possible way to inform the implementation of the Act’s provisions. New Pathways currently facilitates the sharing of survivors’ views in a number of ways including the use of evaluation and feedback forms, on-line surveys and regular forums. It is only with engagement with our own client group that we can be sure that we are continually developing and enhancing the most appropriate range of specialist client services. However, New Pathways does not feel it would be appropriate, at this stage, to ask survivors about specific elements of the implementation of the Act’s provisions. It is our understanding that most clients would currently be unaware of the specific legislation and intentions of the Act.

3. Are survivors of abuse beginning to experience better responses from public authorities as a result of the Act, particularly those needing specialist services.

New Pathways feels that it would be premature to assess whether survivors of abuse are beginning to experience better responses from public authorities as a result of the Act. New Pathways does not feel that it would be appropriate to question survivors directly about any changes that have resulted from the Act at this stage.

4. Does the National Advisor have sufficient power and independence from Welsh Government to ensure the implementation of the Act.

New Pathways does not feel that the National Advisor currently has sufficient power and independence from Welsh Government to ensure the implementation of the Act. New Pathways feels that it is too early to assess the impact of the National Adviser to date. However, New Pathways does feel that it is crucial for the National Adviser to have sufficient power and independence from Welsh Government in order to ensure the successful implementation of the Act going forward.

5. To what extent is the Good Practice Guide to Healthy Relationships successfully influencing the development of a whole school approach to challenging VAWDASV.

New Pathways does not feel equipped to respond fully or meaningfully to this question at this time. New Pathways feels that it would be difficult to measure the extent to which the Good Practice Guide to Healthy Relationships has successfully influenced the development of a whole school approach to challenging VAWDASV. While it is clear that there is now an imperative for all schools to challenge VAWDASV and to actively promote healthy relationships it is not clear whether all schools have responded with the same level of enthusiasm and whether a truly consistent and cohesive whole school approach now truly exists. While this situation may become clearer in time it is unlikely that New Pathways, or other similar organisations, will be able to comment on this meaningfully in the future without access to data which contrasts the impact of the Good Practice Guide across different schools and different areas.

It is of concern to the Group, therefore, that the current draft strategy lacks substance and fails to acknowledge the disproportionate experiences and impact of abuse on women and children. The proposed priorities are narrow in scope and do not clearly align with the objectives and vision, and unfortunately it recreates a silo approach by only focussing on what one Welsh Government department can deliver, at a time when national, regional and local collaboration to end violence against women is essential.

· The definitions used in the national strategy are highly problematic and potentially damaging to achieving effective prevention work in Wales. Definitions are vital because they will steer regional and local commissioning and monitoring, however the proposed definitions are not in line with the United Nations, international and UK recognised definitions of domestic abuse and violence against women. This is a backward step from the 6 year ‘Right to be Safe’ violence against women strategy in Wales (2010-2016), which included the internationally accepted definition of violence against women, which placed it clearly within an equality and human rights framework. Losing this approach in Wales places us out of step with the UK Government and other devolved nations (e.g. the Home Office Ending Violence Against Women and Girls Strategy 2016-2020). The VAWAG includes expert legal advisors on violence against women, and we have offered to advise Welsh Government on the matter of the importance of adherence to international definitions, which we hope will be taken up.

· The Strategy lacks a commitment to funding for independent specialist services in the third sector, despite previous Ministerial commitments to ensure that a model is developed to provide long term sustainable funding for specialist services from 2017/18 to ensure the future of third sector specialist domestic abuse, sexual violence, and violence against women services in Wales. However there is no regard for how specialist third sector services should be sustained and developed. These services are vital to enable public services to deliver their statutory duties to prevent violence against women, and protect and support survivors e.g. under the National Training Framework and Ask and Act policy framework. Yet these services are severely depleted in terms of capacity and resources and several face closure next year if funding cuts continue. Again, by not investing in specialist third sector services nationally through the use of dedicated ring fenced funding sourced from across Government departments (like Scottish and Westminster Governments have done and as required by the Istanbul Convention), Wales risks falling out of step with the UK in sustaining its national network of specialist services.

· Primary prevention – a key statutory duty for public services, as introduced by the Act – remains weak in the strategy and simply focussed on raising awareness without including any evidence-based interventions that are known from research to contribute to the prevention of violence against women. We would like to see a range of prevention activities priorities over the life of the strategy (5 years) which are developed and monitored in the longer term. The specialist sector in Wales already undertakes prevention work and collaborative partnerships with specialist services would add value to the work of public services, and should be further explored.

The VAWAG membership is concerned there is no opportunity to contribute to the accompanying delivery plan, which we understand will be published along with the strategy on 6 November. The group holds significant expertise within its membership, and whilst some members have provided pre-consultative advice on the content of the strategy, this has not been incorporated. We again offer to provide a ‘task and finish group’ to improve the strategy to ensure it is the best it can be so that Wales continues to lead the way on violence against women prevention in the UK.

Whether the National Adviser has sufficient power and independence from the Welsh Government to ensure implementation of the Act?

The VAWAG welcomes the role of the National Adviser as a mechanism to provide leadership on violence against women in Wales and to advise the Minister and relevant authorities on the actions required. However at present it remains to be seen how independent and effective the role is. The VAWAG felt there was a lack of synergy with the role and the draft strategy. There is particular concern that the role lacks time and resources, currently it is a part time post with no budget or support to carry out the role to the full potential.

In summary, the VAWAG would appreciate it of a Committee member could ask the Cabinet Secretary if the refreshed violence against women, domestic abuse and sexual violence strategy will:

1. Recognise and adopt the internationally accepted definition of violence against women and the UK definition of domestic abuse, to ensure consistency in strategy, commissioning and monitoring developments in Wales?

2. Include a model for long term sustainable funding for the specialist violence against women, domestic abuse and sexual violence services in the third sector in Wales, building on recent announcements by DWP on the need for a new long term model for funding refuges?

3. Minimise silo working and encourage cross Government, national and local collaboration and commitments to invest in the prevention, protection and support of violence against women, domestic abuse and sexual violence in Wales, working in partnership with specialist third sector services already working on prevention.